Taking into consideration aspects like tax regime, substance requirements and confidentiality, we would strongly recommend that you choose one of the following jurisdictions for your holding structure:

Malta: Dividend income can be 100% exempt of corporate tax, if the Maltese company a) holds at least 10% of the shares of the foreign subsidiary, or b) invests more than EUR 1.5 million in its subsidiary. Note that the subsidiary company must also either a) be domiciled in the European Union, b) pay at least 15% corporate tax in its country of domicile or c) generate its revenue mainly from trading activities.

The Netherlands: The Dutch B.V. offers a great holding regime, with no minimum period for holding shares, no corporate income tax on dividend income and no capital gains tax from the sale of shares. However, you must adhere to a number of participation exemption rules: foreign subsidiaries must either a) be trading companies, or b) pay corporate tax of at least 10% in the countries where they are registered.

Singapore: Corporate taxation in Singapore works on a one-tier basis, meaning that the 17% tax on corporate income is charged once and is final. Dividends distributed to shareholders are therefore not subject to additional withholding tax.